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valuation date - short CB plan year for termination


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Small non-PBGC cash balance plan used a 12/31 valuation date.

Froze 3/31/20, terminated 5/31/20, assets all out on 8/12/20.  So I'm prepping final report and SB for actuary to sign ahead of 6/15 extended deadline.

Is 8/12 an okay valuation date to use?  Assets and liabilities both zero at that point since everyone was paid (final assets were just a residual dividend liquidated to pay fees).  Don't want to switch to 1/1/20 because we'd have to assume folks would be hitting 1000 hours and getting a new contribution.  5/31 valuation date would obviously require more review of the numbers the software spits out.

Thanks.

-Bri

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Not disagreeing with Mike, but 8/12 would definitely NOT be ok.  The plan didn't exist on 8/12/20 since it was terminated on 5/31/20.  I think your val date would be 5/31.

The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.

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Thanks, guys - I think we're going to go with the 1-1 date and acknowledge the amendment to eliminate the NC, just to avoid a mid-year valuation date that ties to the termination date but not the end of the short plan year.  A valuation reflecting zero benefits and assets did seem a little *too* easy!

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